Vincent Wrencher, Sr. v. State

ACCEPTED 03-15-00438-CV 8409948 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/30/2015 1:55:00 PM JEFFREY D. KYLE CLERK CAUSE NO. 03-15-00438-CV

FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE THIRD DISTRICT OF TEXAS 12/30/2015 1:55:00 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk

VINCENT WRENCHER, SR.,

Appellant, v.

THE STATE OF TEXAS,

Appellee

ON APPEAL FROM THE COUNTY COURT AT LAW NO. 8

TRAVIS COUNTY, TEXAS

APPELLEE'S UNOPPOSED MOTION FOR AN EXTENSION TO FILE

APPELLEE'S BRIEF

Respectfully submitted,

Kenny Conyer

Assistant City Attorney

The City of Austin, Texas

700 East ih Street

Austin, Texas 78701

512-974-4804 office

512-974-1244 fax

[email protected]

Bar No. 24065074 TO THE HONORABLE THIRD COURT OF APPEALS:

COMES NOW, the State of Texas, Appellee, and files this Motion for Extension of Time to File Appellee's Brief, and in support thereof would show the Court as follows:

1. Appellee believes its response brief will be due on December 30, 2015.

Appellee requests an extension of one month, to February 1, 2016, to file its brief. This is Appellee's first request for an extension in this case.

2. The Assistant City Attorney assigned to this case, Kenny Conyer, IS unable to complete a response brief due to the holiday work schedule combined with a heavy work load. Appellee notes the Court has granted two extensions for the Appellant.

PRAYER

Wherefore, the State would, for the reasons stated herein, request that the Court grant this motion for an extension of time.

Respectfully Submitted,

Anne Morgan City Attorney State Bar No. 14432400 State Bar No. 24065074

Assistant City Attorney for

The City of Austin, Texas

700 East ih Street

Austin, Texas 78701

512-974-4804 office

512-974-1244 fax

[email protected] CERTIFICATE OF SERVICE

This is to certify that I have served a copy of the foregoing on all parties, or their attorneys of record, in compliance with the Texas Rules of Appellate Procedure, this~ day of December, 2015.

Via Certified Mail, _ _ _ _ _ _ _ to:

Mr. Vincent Wrencher Senior

1117 Briargate

Austin, Texas 78753 CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.l(a)(5), I certify that I have conferred, or made a reasonable attempt to confer, with all other parties, which are listed below, about the merits of this motion with the following results: Vincent Wrencher Sr., Prose opposes motion

X does not oppose motion agrees with motion would not say whether motion is opposed did not return my message regarding the motion